I, Maurice Evangalist Sorzano, Jr., do hereby declare and say that: 

1. I am an ethnically Black inmate facing sex charges, and who is incarcerated within the Shasta County Jail [now High Desert], which is located at 1655 West Street, Redding, CA 96001. 

2. Due to my charges and ethnicity, I have suffered prejudice and physical violence in Shasta County. 

3. On January 7, 2002, while housed in POD-1-C of the Jail, I was physically intimidated and threatened by a group of inmates, which included Thomas Burger, a former Redding defense attorney who is now incarcerated following his conviction on several felony drug charges. 

4. Thomas Burger made the statement to me, "I have already burned fifteen of our kind in the last year!" This threat and other conversation inferred that Burger had provided, and conspired to provide, ineffective assistance of counsel to no less than 15 defendants facing criminal charges of a sexual nature, and/or who were an ethnic minority. 

5. I believe that other inmates who were housed in POD-1-C on January 7, 2002, also heard Thomas Burger's statements, and are potential witnesses t his admissions of ineffective assistance of counsel. 

6. I believe that there are no less than 15 persons who were represented by Thomas Burger in the last year who suffered from ineffective assistance of counsel, and who therefrom did not receive a fair trial, or who entered into an uninformed inappropriate plea bargain that was not in their best interests. 

7. I believe that the appropriate agencies should investigate and identify these 15 people who were convicted without effective assistance of counsel, and that these cases should be reviewed for appropriate action. 

8. Based on the above information, I further believe that the entire Shasta County Justice System should be investigated for possible abuse of rights of sex offenders, and persons of ethnic minority. 

I have read the foregoing statements and do declare under penalty of perjury that they are true and correct. Executed this 8^th day of January 2002. 
 

Signed: Maurice E. Sorzano, Jr. 
Declarant